Epstein Secrets

ed as trusts for U.S. federal income tax purposes are subject to special rules). If the Fund is not engaged in the conduct of a trade or business in the United States, Non-U.S. Partners in the Fund's shares of income and gains from sources other than the United States (e.g., generally, interest or dividends paid b

"Treasury Regulations") to be treated as a U.S. person. For purposes of this section, a Ron-U.S. Partner" means a Limited Partner that is neither a U.S. Limited Partner nor a partnership (or any other entity treated as a partnership) for U.S. federal income tax purposes. A 'U.S. Tax-Exempt Partner" is a U.S.

ity and other derivative products, including, without limitation, (i) futures contracts (and options thereon) relating to stock indices, currencies, United States government securities and securities of non-U.S. governments, other financial instruments and all other commodities, (ii) swaps, options, contracts

the Service so as to relieve the Limited Partners of these reporting obligations. Regulations also generally impose a reporting requirement on any U.S. Limited Partner which, at any time during the taxable year of the Master Partnership, owns (indirectly or by attribution) more than 50% of the capital or p

ity and other derivative products, including, without limitation, (i) futures contracts (and options thereon) relating to stock indices, currencies, United States government securities and securities of non-U.S. governments, other financial instruments and all other commodities, (ii) swaps, options, contracts

the Service so as to relieve the Limited Partners of these reporting obligations. Regulations also generally impose a reporting requirement on any U.S. Limited Partner which, at any time during the taxable year of the Master Partnership, owns (indirectly or by attribution) more than 50% of the capital or p